Davis v. New Zion Baptist Church

811 S.E.2d 725, 258 N.C. App. 223
CourtCourt of Appeals of North Carolina
DecidedMarch 6, 2018
DocketCOA17-523
StatusPublished
Cited by1 cases

This text of 811 S.E.2d 725 (Davis v. New Zion Baptist Church) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Davis v. New Zion Baptist Church, 811 S.E.2d 725, 258 N.C. App. 223 (N.C. Ct. App. 2018).

Opinion

DIETZ, Judge.

*224 This dispute between a church and some of its former members returns to us for a second time. Our review is constrained by the mandate in the previous decision of this Court, and the limits on judicial intervention in the governance of religious bodies established in the First Amendment to the United States Constitution.

As explained below, we affirm the trial court's judgment that, applying neutral principles of law, the church did not follow the procedure established in its bylaws when it attempted to amend them. Because the bylaws govern some non-ecclesiastical issues involving church property and contract rights, courts have the power to adjudicate this issue. With respect to the remaining issues on appeal, concerning removal and election of church deacons and trustees, the bylaws are silent. The courts can play no role in the resolution of those issues. We therefore affirm the trial court's order in part and vacate the order in part.

Facts and Procedural History

In 2013, Plaintiffs, all of whom were active, voting members of New Zion Baptist Church, sued the Church and its pastor, Henry Williams, Jr.

All of Plaintiffs' claims stemmed from the Pastor's management of Church finances and a decision by the Church in 2013 to amend the Church bylaws, changing various tenets of Church doctrine as well as other aspects of the Church's day-to-day operations. The trial court denied the Church's motion to dismiss for lack of subject matter jurisdiction, rejecting the argument that the First Amendment barred the courts from adjudicating these claims.

This Court affirmed the trial court in part. Davis v. Williams , 242 N.C. App. 262 , 774 S.E.2d 889 (2015). We held that courts had the power to adjudicate Plaintiffs' claim with respect to the Church's breach of its own bylaws, but only to the extent that this claim involved application of neutral principles of law to Church rules that did not involve doctrine or religious practice. Id.

On remand, the trial court entered summary judgment holding that the Church "violated its Bylaws in its 2013 attempts to vote on proposed amendments" and therefore those amendments were void. The trial court also found that, because the existing bylaws were "silent as to the process for removing deacons and trustees," the trial court could not play any role in reviewing the removal of those officers from their posts. But the trial court nevertheless ordered the Church to hold an election *225 "to fill vacancies in the office of deacon and trustee ... at the next regular business meeting of the church, but in any event, no later than ninety (90) days from the filing of this Order." Both parties timely appealed portions of the trial court's ruling.

Analysis

I. Standing

We begin with the Church's argument that Plaintiffs lack standing to pursue their claims.

Standing is a jurisdictional principle that stems from the notion of "justiciability." It is designed to ensure that a party seeking relief from the courts has a sufficient stake in the controversy to justify adjudication of the dispute. See Neuse River Found., Inc. v. Smithfield Foods, Inc ., 155 N.C. App. 110 , 114, 574 S.E.2d 48 , 51-52 (2002). There is a well-established body of case law governing standing in the federal courts. But because "North Carolina courts are not constrained by the 'case or controversy' requirement of Article III of the United States Constitution," our State's standing jurisprudence is broader than federal law. Id. at 114 , 574 S.E.2d at 52 . Although our Supreme Court has declined to set out specific criteria necessary to show standing in every case, the Supreme Court has emphasized two factors in its cases examining standing: (1) the presence of a legally cognizable injury; and (2) a means by which the courts can remedy that *728 injury. See, e.g., Goldston v. State , 361 N.C. 26 , 34-35, 637 S.E.2d 876 , 881-82 (2006).

Here, Plaintiffs were voting members of the Church in good standing at the time of the alleged violations of the Church bylaws, and at the time they filed this lawsuit. They alleged that they were harmed, as voting members of the Church, by the Church's failure to follow the proper voting procedure when amending the bylaws.

But the Church asserts in its brief that, "[a]fter this lawsuit was filed, plaintiffs were advised ... they are no longer members of the church." Thus, the Church argues, Plaintiffs no longer have standing because, as non-members of the Church, they have no right to challenge the Church bylaws or voting practices.

We disagree. Because the injury Plaintiffs allegedly suffered occurred during a time that the parties concede they were active members of the Church, and because that injury has not been resolved or redressed among these parties, we hold that Plaintiffs have a sufficient stake in the controversy to confer standing despite their removal as *226 members after the lawsuit began. See Metcalf v. Black Dog Realty, LLC , 200 N.C. App. 619 , 625, 684 S.E.2d 709 , 714 (2009).

II. Trial court's entry of summary judgment

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Bluebook (online)
811 S.E.2d 725, 258 N.C. App. 223, Counsel Stack Legal Research, https://law.counselstack.com/opinion/davis-v-new-zion-baptist-church-ncctapp-2018.